"While making payments in two installments is welcome, we strongly encourage [HHS] to allow self-insured employers to have the option, at their discretion, to pay the entire reinsurance fee in January of each year should they find it beneficial to do so.... After carefully reviewing the NPRM and consulting with our members, we wish to address four major items of concern: [1] Self-insured self-administered plans should be a contributing entity for the transitional reinsurance program; [2] The definition of third party administrators is unnecessarily complicated; [3] Self-insured group health plans should not be required to pay the costly treasury contribution amount; and [4] Excess collections should not be used to increase coinsurance rates."  MORE >>